In 2009, anti-choice lawmakers continued their relentless attacks on a woman's right to choose in legislatures throughout the country. At the federal level, anti-choice members of Congress attempted to use health-reform legislation as an opportunity to impose new limitations on women's reproductive freedom. The House passed a health-reform bill that includes sweeping new restrictions on women's access to abortion care, including provisions that would even make it virtually impossible for women purchasing insurance in the new health-care system with their own, private funds to obtain abortion coverage. At the time of this publication's printing, the Senate had not yet passed its version of the bill; however, several threats continue to loom, including a similar ban as well as measures that would grant broad license to health-care providers and entities (including hospitals, HMOs, and insurance companies) to refuse to provide or cover medical services and proposals to reinstate funding for failed "abstinence-only" programs.

At the state level, among the several newly enacted anti-choice laws, two states implemented measures that ban a safe, medically appropriate abortion procedure with no exception to protect a woman's health – laws that are enforceable due to the Supreme Court's decision to reverse precedent and uphold the Federal Abortion Ban in 2007. In addition, several states considered so-called "personhood" measures intended to impose near-total bans on abortion. These bills gained traction in some legislatures; fortunately, however, no states enacted such provisions.

In addition to the several states that considered bills that would place bans on access to abortion, states also considered and enacted a wide variety of other anti-choice bills, including those that support discredited and dangerous "abstinence-only" programs, block women's access to birth control, force providers to tell women ideological and factually incorrect information about abortion care, restrict young women's access to abortion services, and place unnecessary and burdensome requirements on abortion providers. Puzzlingly, anti-choice legislators continued their insistence on opposing measures to prevent unintended pregnancy and therefore reduce the need for abortion, while instead focusing on divisive measures to make abortion care more difficult to obtain for women who need and choose it. In addition, several courts upheld anti-choice state provisions in question, further legitimizing these harmful laws and opening the door for other states to enact similarly restrictive measures.

Even with Roe's core protections still in place, 87 percent of counties in the United States have no abortion provider, according to The Guttmacher Institute. But opponents of choice are not satisfied, pushing forward with legislative measures that run the gamut from granting pharmacists the right to refuse to fill birth-control prescriptions to outright bans on abortion in all circumstances, even when a woman's health is in danger.

Measures enacted:

• 14 states enacted 29 anti-choice measures in 2009.
• Arkansas enacted the most anti-choice legislation in 2009, with four measures.
• Between 1995 and 2009, states enacted 610 anti-choice measures—including 29 in 2009 alone.

Anti-choice legislation enacted in 2009 included:

• Both Arkansas and Arizona enacted legislation that bans a safe, medically appropriate abortion procedure with no exception to protect a woman's health. These laws have only limited exceptions to protect a woman's life.
• Arizona enacted an omnibus anti-choice law that, among other things, mandates notarized parental notice prior to a young woman obtaining an abortion, requires women to receive a state-mandated lecture prior to obtaining abortion care and prohibits abortion unless women wait an additional 24 hours after receiving the lecture, forbids certain qualified health-care professionals from providing abortion services, and allows certain individuals or entities to refuse to provide abortion services and to refuse to provide or dispense contraceptives. (A court enjoined several of these provisions in September 2009.)
• Virginia enacted a law that establishes "Choose Life" license plates. A portion of the proceeds from these plates funds anti-choice organizations known as "crisis pregnancy centers" that target women considering abortion and often mislead, coerce, and intimidate them.